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Course Details

Course Information
  • smart_display Format

    Live Online with Live Q&A

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Tuesday, June 3, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This course will provide tax advisers, professionals, and preparers with a solid overview and explanation of key income tax treaty provisions needed to determine whether their clients may take treaty-based return positions. The panel will discuss income tax treaties that exist between the U.S. and over 66 of its trading partners. The talk will focus on why treaties are so important to U.S. businesses as well as to U.S. investors in foreign securities. The panel will talk about one or two specific treaties to illustrate the value of treaties in general.

Faculty

Patrick J. McCormick
Partner
Rimon, P.C.

Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. He is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.

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Arti Patel
Manager, Global Mobility Tax
CliftonLarsonAllen

Ms. Patel is an experienced Tax Manager at CLA, where she leads the delivery of comprehensive tax solutions to corporate clients, particularly in relation to their mobile employees. With a strong background in expatriate tax and global mobility, Ms. Patel has developed specialized knowledge in relocation, tax, social security, equity compensation, and payroll compliance. She has a proven track record of collaborating with clients, vendors, and all levels of executive management to drive strategic direction and deliver exceptional results. Ms. Patel's expertise spans tax preparation services for both US domestic and international assignees, as well as tax advisory services. She focuses on business development and oversees the integrated delivery of expatriate tax services. Leveraging over 8 years of experience, including 3 years with a Big 4 public accounting firm, Ms. Patel provides professional guidance in global mobility and international taxation. 

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Auberie Silvain
Attorney
Greenberg Glusker Fields Claman & Machtinger LLP

Ms. Silvain is an Associate in the Private Client Services Group, specializing in cross-border U.S. tax planning and strategies  for clients in the U.S. and abroad. Her practice focuses on high-net-worth individuals and closely-held businesses with various U.S. international tax issues from inbound and outbound transactions and operations. Ms. Silvain has experience developing tax planning strategies to achieve favorable tax positions based under income tax treaties between the U.S. and other countries. She assists clients with pre-immigration planning, foreign investments in the U.S., U.S. residency planning and management, and expatriation planning. Ms. Silvain also participates in international merger and acquisition projects, which includes tax structuring and due diligence on acquisitions, dispositions and organizational restructuring.

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Description

The United States has income tax treaties in force with over 66 countries. The treaties are intended to eliminate or reduce double income taxation. Benefits are available to nonresident aliens (and, to a limited extent, to U.S. citizens living abroad) concerning U.S. federal income taxes and to U.S. citizens and residents relating to foreign country income taxes. Tax advisers working with nonresident aliens with U.S. investments or business activities and U.S. individuals with foreign source income need to know the procedures for claiming and reporting treaty-based return positions.

While each income tax treaty has its specific terms and requirements, common themes and terminology are found in all U.S. income tax treaties. Under most income tax treaties, U.S. taxpayers may claim exemption from source country taxation for personal services income. Other provisions include reduction or waiver of withholding taxes on interest and dividends.

A foreign person claiming a tax benefit under a U.S. income tax treaty may report the position on IRS Form 8833. Alternatively, a taxpayer may take a silent treaty position. Failure to file Form 8833 with the IRS may result in a $1,000 penalty for each year an individual fails to disclose their treaty position. The disclosure must include specific information about the treaty, including the article of the treaty that applies, and the Internal Revenue Code section changed by the claimed treaty position.

Listen as the panel provides comprehensive guidance on how to read and interpret key income tax treaty provisions, report treaty-based positions on Form 8833, how to claim reduction or exemption from foreign income taxation under a treaty, and complete Forms W-8BEN and W-8BEN-E to establish an exemption from U.S. withholding taxes.

Outline

  1. Basic structure of income tax treaties
  2. Common features of tax treaties
  3. Persons who can benefit from an income tax treaty
  4. Application of the "savings clause" to U.S. citizens
  5. Personal services income
  6. Interest and dividends
  7. Compliance and forms

Benefits

The panel will discuss these and other critical matters:

  • Purposes of income tax treaties
  • Persons who can claim benefits
  • Common residency provisions and tie-breakers for dual residents
  • Savings clauses applicable to U.S. citizens
  • Exemptions for personal services income
  • Treatment of interest and dividends
  • How to complete Forms 8833 and W-8BEN with examples

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify standard clauses in all U.S. treaties
  • Determine when a taxpayer should complete Form W-8BEN
  • Decide where to find reduced dividend rates in treaties
  • Ascertain when a taxpayer should file Form 8833

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).